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2013 /JUN /04 /TUE 03:17 PM Rich A Munson FAX No,303 932 0384 P,003 <br />Janet Binns <br />Division of Minerals & Geology <br />June 4, 2013 <br />Page 2 <br />Engineering estimates at the time MW -NW was designated as a groundwater monitor well <br />concluded that: "Based on the volume of the mine workings (estimated at 5,700 acre - feet), an <br />inflow rate of 20 acre-feet per year, and assuming no ground water seepage, it would take <br />approximately 300 years for the abandoned mine workings to totally fill." <br />Consistent with this prediction, monitoring data to date has not observed any water in MW- <br />NW. Accordingly, the likelihood of MW -NW actually encountering water in the mine workings <br />prior to it being reclaimed in accordance with the approved reclamation plan is extremely unlikely. <br />Additionally, other monitor wells in the approved water monitoring program will provide <br />groundwater data. <br />EF Coal also believes, based on communications with other coal operators, that the Division <br />is applying inconsistent standards to similarly situated coal operators with regard to (1) remediation <br />of damaged groundwater monitoring wells and (2) the necessity of groundwater monitoring <br />subsequent to mine closure. <br />Finally, EF Coal is preparing additional information to support the previously fled TR -40 <br />which will also provide additional support for EF Coal's position that MW -NW continues to <br />function as intended and accordingly that the NOV should be vacated by the Board, We will submit <br />the information to the Division for review as soon as it is available to allow consideration of the <br />information prior to the Board Hearing which we understand will be scheduled for hearing dates <br />within 60 days of our request. We understand that the July meeting of the Board is currently <br />scheduled for 17 July. <br />Sincerely, <br />T. Muzxsorr <br />cc: George V. Patterson <br />Sent via Facsimile 303 -832 -8106 & Email: janet.binns @state.co.us <br />